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Baseline Policy in MA and CA IEPEC slides

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Headquarters: 120 Water Street, Suite 350, North Andover, MA 01845 With offices in: CA, CT, ME, NY, OR, TX, VT www.ers-inc...

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 Offices in MA, ME, CT, NY, TX, CA, OR
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 Convince you to create a baseline policy
 Share procedures lessons learned from MA, CA
 Highlight technical similariti...

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Baseline Policy in MA and CA IEPEC slides

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Presentation given at the IEPEC 2017 Conference in Balitmore, by Jon Maxwell of ERS. Massachusetts and California tied for first place in ACEEE 2016 State Energy Efficiency Scorecard. They also have made considerable investment in evaluation. It is notable, then, when these two leading states choose to make major policy decisions regarding the same topic at nearly the same time. Both states chose to update their baseline policy in 2016. This presentation describes key baseline principles that have been formalized in the states’ respective policy documents, compares and contrasts the policies, and provides a narrative discussion of the historical context of the changes.

Presentation given at the IEPEC 2017 Conference in Balitmore, by Jon Maxwell of ERS. Massachusetts and California tied for first place in ACEEE 2016 State Energy Efficiency Scorecard. They also have made considerable investment in evaluation. It is notable, then, when these two leading states choose to make major policy decisions regarding the same topic at nearly the same time. Both states chose to update their baseline policy in 2016. This presentation describes key baseline principles that have been formalized in the states’ respective policy documents, compares and contrasts the policies, and provides a narrative discussion of the historical context of the changes.

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Baseline Policy in MA and CA IEPEC slides

  1. 1. Headquarters: 120 Water Street, Suite 350, North Andover, MA 01845 With offices in: CA, CT, ME, NY, OR, TX, VT www.ers-inc.com BASELINE POLICY ENHANCEMENT IN MASSACHUSETTS & CALIFORNIA August 8, 2017 1
  2. 2.  ERS  ≈90 energy efficiency & renewable experts  Offices in MA, ME, CT, NY, TX, CA, OR  Evaluation, studies, implementation, consulting  Presenter: Jon Maxwell, PE  Co-authors: Ralph Prahl, Sue Haselhorst ABOUT ERS & AUTHORS 8/8/2017 IEPEC 2017 - Baltimore 2
  3. 3.  Convince you to create a baseline policy  Share procedures lessons learned from MA, CA  Highlight technical similarities & differences  Get at least 5 people to look at the paper PRESENTATION GOALS 8/8/2017 3IEPEC 2017 - Baltimore
  4. 4. BASELINE POLICY—WHY BOTHER? (CA) ntotal = 240 ≈10% hit on RR! 8/8/2017 IEPEC 2017 - Baltimore 4
  5. 5. -10% -8% -6% -4% -2% 0% 2% 4% 6% 8% Tracking Error Gas Billing Error Quantity Baseline Efficiency Final Efficiency Operational Baseline Operational Non Discernable Non Operable Other %ofTotalError Weighted Discrepancy BASELINE POLICY—WHY BOTHER? (MA) ≈8%+ hit on RR! 8/8/2017 IEPEC 2017 - Baltimore 5
  6. 6. BASELINE POLICY—WHY BOTHER? (NY) Category Description This category accounts for typo revisions, incorrect extraction of This category accounts for a ba (L050) This category accounts for thos clearly violate program tenets. (L Administrative: 46 measures Baseline: 33 measures VFD screening method: 10 measures Unsubstantiated savings claims: 7 measures This category accounts for savin supported with site based analys Inoperable Equipment: 1 measures This category accounts for the e described in the project docume Quantity or size: 41 measures This category accounts for the d compared with the project docum Technology: 27 measures This category accounts for the d observed by the evaluators versu Applicant used deemed value: 16 measures This category accounts for diffe operation) and the evaluated val Interactivity: 38 measures This category accounts for the i interactivity is lighting which typ Operation/Load Profile: 81 measures This category accounts for the d factor, part load profile, or temp Other/Weather: 2 measures This category accounts for the w Category Description Negative Impact on RR Positive Impact on RR -8% 2% -6% 1% -8% 0% -2% 0% -2% 0% -1% 0% -1% 0% -2% 3% 0% 1% -8% 3% -1% 0% This category accounts for typographic errors, failure to update tracking with application revisions, incorrect extraction of savings from spreadsheets and the like. (L126) This category accounts for a baseline adjustment from early replacement to normal replacement. (L050) This category accounts for those VFD measures that did not meet program eligibility criteria or clearly violate program tenets. (L077) Administrative: 46 measures Baseline: 33 measures VFD screening method: 10 measures Unsubstantiated savings claims: 7 measures This category accounts for savings estimates based on a claimed savings fraction which was not supported with site based analysis, measurement, or evidence from an applicable study. (L097) Inoperable Equipment: 1 measures This category accounts for the equipment discovered to not be operational or controlled as described in the project documents. (LR21) Quantity or size: 41 measures This category accounts for the differences in the quantity or size of an installed measure when compared with the project documents. (L062) Technology: 27 measures This category accounts for the differences in the actual baseline and installed technologies observed by the evaluators versus the project documented technologies. (L134) Applicant used deemed value: 16 measures This category accounts for differences in the NYTM specified parameters (usually hours of operation) and the evaluated value. (L134) Interactivity: 38 measures This category accounts for the interactive effects of measures. A good example of measure interactivity is lighting which typically has interactive cooling and heating effects. (LR02) Operation/Load Profile: 81 measures This category accounts for the deviations in the projected equipment load profile (part load factor, part load profile, or temperature profile) or the operational schedule. (L106) Other/Weather: 2 measures This category accounts for the weather normalization applied by the evaluators. (L084) Close to CA’s 13% frequency, likely similar hit on RR! ≈5% hit on RR! 8/8/2017 IEPEC 2017 - Baltimore 6
  7. 7. BASELINE POLICY—WHY BOTHER? Can these be fixed in advance? Inoperability or facility shutdown issues? Accidental errors? Hours? Predicted load factors? Baseline? × No × Not really, maybe specify QC × Not really, maybe deem × Not really maybe deem  Yes, baseline can be aligned, in advance, through policy articulation 8/8/2017 IEPEC 2017 - Baltimore 7
  8. 8. BASELINE POLICY—WHY BOTHER? 8/8/2017 IEPEC 2017 - Baltimore 8
  9. 9. Headquarters: 120 Water Street, Suite 350, North Andover, MA 01845 With offices in: CA, CT, ME, NY, OR, TX, VT www.ers-inc.com PROCEDURES & CONTENT COMPARISON 9
  10. 10.  Stakeholder engagement  Significant development period  1 to 2 years  Longer than planned, extra iterations  Professional facilitation DEVELOPMENT PROCEDURES – COMMON IEPEC 2017 - Baltimore8/8/2017 10
  11. 11.  Single document (MA)  C/I focus (MA)  Implementer engagement (CA)  Regulatory-driven (CA)  Final document authorship  CPUC in CA  Consultant team in MA DEVELOPMENT PROCEDURES – DIFFERENCES IEPEC 2017 - Baltimore8/8/2017 11
  12. 12. KEY TECHNICAL SIMILARITIES IEPEC 2017 - Baltimore8/8/2017 12  Code and ISP basis  for commodity measures  Logic flowcharts (MA more)  Preponderance of evidence (POE) (CA more)  Dual baseline (new to MA eval)  Pre-installation evaluator engagement  Non-regressive baseline (MA 3 exceptions)  Tiers of rigor (CA more)  Industrial capacity expansion  New construction  Post-project production rate governs
  13. 13. TECHNICAL HIGHLIGHTS (1 OF 2) – CORE BASELINE DEFINITION IEPEC 2017 - Baltimore8/8/2017 13  MA: Baseline is “…condition absent the measure”  Not “absent the program”  Think: What if the technology didn’t exist  CA: Baseline is “Table 1” Alteration Type Delivery Savings Determi- nation Shell, Bldg System, Add- On Behavioral, RCx, Operational Normal replacement Accelerated replacement and repair eligible Code Code Code Code Calculated Existing Existing Code Dual Deemed Existing Existing Code Dual Normalized Metered Existing Existing Existing, Program Design Existing RCT/ experi- mental Existing Existing Existing Existing Existing Standard Practice Dual New Up- Mid-stream Non-Bldg, Ag, Process Existing Blgs (incl. major altera- tions) Down- stream
  14. 14. IEPEC 2017 - Baltimore8/8/2017 14  Free ridership questions must be relative to the gross baseline  Especially vulnerable if ex post evaluator changes baseline  MA spin-off working group to avoid overlap penalty o “Absent the measure” vs. “absent the program” is tricky to word o New framework in pilot stage  CA evidence of free ridership guidance  CA ex ante binding free ridership assessment TECHNICAL HIGHLIGHTS (2 OF 2) – FREE RIDERSHIP
  15. 15. APPLICATION COMPARISON IEPEC 2017 - Baltimore8/8/2017 15  Policy is binding for evaluators in MA, for all in CA  CA ex ante review findings are binding to implementers immediately  MA now evaluating lifetime savings RRs  Informational-only thru 2018
  16. 16. SUMMARY IEPEC 2017 - Baltimore8/8/2017 16  Low realization rates? Baseline policy can help  Stakeholder process builds understanding, buy-in  Use MA & CA for reference, but each jurisdiction has different needs. Trade-offs:  Specificity vs. flexibility  Ideal theory vs. practicality  Guidance vs mandates  A worthwhile investment
  17. 17. TECHNICAL HIGHLIGHTS INDUSTRY STANDARD PRACTICE IEPEC 2017 - Baltimore8/8/2017 17  For new/replace on failure, ISP is baseline if no code or standard  Not minimum efficiency commonly installed  What if code/std exists and ISP differs? MA:  If ISP exceeds code, use ISP. Careful of NTG wording!  If ISP is below code: o If a code compliance program, use code/std o If no compliance program, use ISP
  18. 18. KEY TECHNICAL DIFFERENCES IEPEC 2017 - Baltimore8/8/2017 18  Focus on principles (MA) vs. specifics (CA)  Free ridership in scope for CA ex ante review process  MA emphasis on difference between commodity & unique measures  CA emphasis on tiers of rigor
  19. 19. CONTACTS Jonathan B. Maxwell, PE VP, Energy & Evaluation jmaxwell@ers-inc.com 979-978-2550 x205 8/8/2017 19IEPEC 2017 - Baltimore

Editor's Notes

  • Probably 60 work on evaluations some of the time, probably 6 dedicated to it. Lots of interdisciplinary training that we believe keeps our staff grounded in both directions.
  • Take time to translate confusing graph
    From CPUC 2013 Custom Impact Evaluation Industrial, Agricultural, and Large Commercial, Source cited in paper,
    Study of 240 measures.
    Baseline change is the 2nd most common reason for adjustment—13% of evaluated measures.
    But! When adjusting, baseline removed an average of 79% of savings at each site.
    Biggest single contributing factor to low RR. ~10% hit on baseline alone (unweighted rough approximation)
    (FYI 44% to 76% gross RR overall in study, depending on PA & fuel)
  • So what? I’ve heard CA is a bunch of unreasonable hardacres…

    From MA Lg CI Eval 2010-2013 Custom Gas
  • Okay, the paper’s about CA & MA. How about anywhere else?

    From NYSERDA IPE 2012 and NCP 2012, respectively.
    Again, common in frequency
    (not shown) higher in energy impact
  • And with the progress made in MA and CA, you have hundreds of thousands of dollars as building blocks already invested, free for your use.
  • MA ~ 30 pages, CA 100s of pages b/t docs

    CA: ALJ-ordered
    Legislatively mandated interpretations, in some cases (AB-802)
    CPUC staff white papers, drafts
    Filings, filed comments, re-issuing
  • ISP = industry standard practice

    MA of course has dozens of examples

    Possible exceptions: (1) 2-year in failed mode; (2) kitchen equipment; (3) prior measure was funded EE measure
  • CA I couldn’t find a single statement of baseline
    CA hot button issues: - What is a “building system”? Fundamental HVAC system type? Yes? Lamp? Most incl CPUC say No. Lighting system? Maybe
    - Are EMS upgrades a BRO?
    Table 1 is evolving
    Last three months working groups continue to refine CA’s working definition. Would be pleased to yield the floor during Q&A for update in that regard.
  • In direct query
    Provide quick simplified example:
    94% efficiency condensing boiler is installed and runs as designed.
    Code is 80% efficiency boiler
    An ISP study concludes that standard practice is an 82% efficient boiler
    Gross savings is evaluated with an 82% baseline. If tracking used an 80% code baseline, gross RR takes a hit.
    The FR interview asks about program influence. It MUST be relative to an 82% ISP, not an 80% code or NTGR will take a hit also, for the same 2%. Bad!
    Maybe mention ERS, DNV, Tetratech
  • CA will note that the ex ante consultants are not the program evaluation consultants, but for the PAs & implementers it is functionally the same.
  • CA will note that the ex ante consultants are not the program evaluation consultants, but for the PAs & implementers it is functionally the same.
  • ISP is not site-specific.

    Stretch code digression only if time.
  • CPUC Decision 16-018-019 “Table 1” specifies baseline type by alteration type, delivery type, alteration type, program type

    CA does not consider the ex ante review process to be impact evaluation but many view it as such.

    More on free ridership in two slides. Hold off from discussion here.

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